Are universities finally complying with EU directive on accessibility?

UK undergraduate disabled students have a consistently lower than average overall satisfaction rate than non-disabled students and are doing less well in terms of continuing their course (0.9 percentage points), degree attainment (2.8 percentage points), and progression onto highly skilled employment or postgraduate study (1.8 percentage points). The UK Office for students October 2020 Insight brief identified that universities need to build considerations of inclusivity and accessibility into curriculum design, programme review, and purchasing of services and equipment; offer alternative formats of lectures and course materials as standard practice; and provide better advice, guidance and training on digital accessibility for staff.

This year university education has been forced to move online due to the health risks from the coronavirus (COVID-19). While this may have had some advantages and disadvantages for students with disabilities compared to their previous on-campus education experience, it has clearly highlighted the importance of digital accessibility.

The 2016 EU directive requires Member States ensure that websites and mobile applications of public sector bodies meet the W3C Web Content Accessibility Guidelines level AA and provide a regularly updated comprehensive accessibility statement on the compliance of their websites and mobile applications. The statement includes: any content not accessible, reasons why and accessible alternatives; a description of, and a link to, a feedback mechanism to notify of compliance failure and request excluded information; and a link to the enforcement procedure for any unsatisfactory response. The directive applies from 23 September 2019 to websites published after 23 September 2018, recorded time-based media published after 23 September 2020 and mobile applications from 23 June 2021.

Conformance cannot be determined using only automatic auditing tools, but needs human analysis as well. The presence of captions in itself does not automatically guarantee conformance to the directive as it will only be through human analysis that you will be sure that the quality of the captions is high enough to conform to the directive.

Finding an affordable way to provide high quality captions and transcripts for recordings is proving very difficult for universities and using automatic speech recognition with students correcting any errors would appear to be a possible solution. It is up to each Member State to decide how to ensure effective enforcement and whether they wish to go beyond the minimum requirement and information about National laws transposing the Directive is available on the EUR-Lex website. Some compliance guidance for UK higher and further education institutions produced by practitioners is provided on the LexDis website.

Research on compliance of accessibility statements has been undertaken in May 2020 covering 1824 entries from a wide variety of organisations in the UK, Denmark, Luxembourg and Spain. The low conformance highlighted by this research (e.g. out of 132 UK Universities only 31 had compliant accessibility statements) would suggest that so far there has been little monitoring and enforcement and that accessibility has not been prioritised by universities.

University senior managers do not appear to regard the risks of not complying with accessibility legislation as important as complying with Health and Safety legislation (for which non compliance could result in life imprisonment) or Data Protection Legislation (for which non compliance could involve very large fines of up to €20 million, or 4% annual global turnover). There would therefore appear to be a risk that Universities treat the Directive and accessibility statement requirement as merely a compliance tick box exercise rather than an opportunity to really enhance digital accessibility and support students with disabilities.

Enthusiastic university staff and students therefore clearly need the support of senior management to develop, monitor and adequately fund digital accessibility policies that embed accessibility as standard across all learning platforms and technologies while providing training for all staff and students.

Editor’s note: We are delighted to be having Mike join us for our discussion on accessibility on 18 November as part of our Media & Learning Online event Scaling up video-based services in Higher Education.


Prof. Mike Wald,

University of Southampton, UK

Mike’s background

More about Mike’s research activities.